Transfer pricing comparability requires functional alignment and permits working capital adjustment, while APA margins cannot govern non-covered years...
Treaty benefit, goodwill depreciation and hedging costs: export commission disallowed, while key business deductions and depreciation claims succeeded...
Undisclosed foreign asset classification requires an unexplained source; unrebutted affidavits and corroborative evidence defeated the Black Money Act...
Power of Settlement commission to rectify or review its order - Settlement commission did not take into account the unabsorbed depreciation – This is a fit case where the power of rectification could and should have been exercised - HC
Power of Settlement commission to rectify or review its order - Settlement commission did not take into account the unabsorbed depreciation – This is a fit case where the power of rectification could and should have been exercised - HC
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